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Snell & Wilmer

IRS Issues Interim Guidance Eliminating the Acknowledgement of Facts and Expanding Access To Dispute Resolution Programs

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The IRS Large Business & International (LB&I) Division published an Interim Guidance Memorandum (IGM) on July 23, 2025, implementing three changes to current LB&I audit procedures. Specifically, the IGM (1) removes the...more

Rivkin Radler LLP

Writing Off A Loan – Simultaneous COD Income and Bad Debt Deduction? Not Necessarily

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If you’ve been around closely held businesses long enough, you know that a transfer of money between a business and its owner, or between two related businesses, is sometimes characterized by the parties as a loan (“related...more

McDermott Will & Schulte

FedEx Defeats Government’s Loper Bright Gambit

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On February 13, 2025, a Tennessee federal district court handed FedEx Corporation its second win in a refund action involving the application of foreign tax credits to what are known as “offset earnings.”[1] Offset earnings...more

Eversheds Sutherland (US) LLP

Tax Bytes: Week of March 3, 2025

Eversheds Sutherland (US) LLP on

Tax developments - The validity of the 245A DRD for indirectly owned foreign corporations - On January 21, 2025, the IRS filed a motion for summary judgment asking the Tax Court to hold that Sysco Corporation (Sysco)...more

McDermott Will & Schulte

IRS Roundup January 13 – 17, 2025

McDermott Will & Schulte on

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 13, 2025 – January 17, 2025. TAX CONTROVERSY-RELATED DEVELOPMENTS - January 15, 2025: The US...more

Jones Day

New Appellate Court Ruling on Priority of Straddle-Year Taxes in Bankruptcy

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A basic tenet of bankruptcy law, premised on the legal separateness of a debtor prior to filing for bankruptcy and the estate created upon a bankruptcy filing, is that prepetition debts are generally treated differently than...more

Freeman Law

Clarifying the Contours of “Reasonable Compensation”

Freeman Law on

The law has always favored the term “reasonable.”  For example, the law affords protection against a negligence lawsuit if a person can demonstrate he or she acted as a reasonable person would have under similar...more

Patterson Belknap Webb & Tyler LLP

District Court Addresses “Straddle Year” Treatment for Federal Income Tax in Bankruptcy

Patterson Belknap Webb & Tyler LLP on

In an appeal of a bankruptcy court’s decision, a district court judge recently addressed the treatment of the “straddle year” for federal income tax under the Bankruptcy Code, which “does not appear to have been decided by...more

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden's 2020 Insights

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Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more

Coblentz Patch Duffy & Bass

Transferee Liability: The [Unlikely] Situation that your Nonprofit Receives a Charitable Gift with Expensive Tax Strings Attached

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The case of Salus Mundi Foundation et al v. Commissioner - On August 15, 2016, the Tax Court decided in Salus Mundi Foundation et al v. Commissioner, T.C. Memo. 2016-154, that two foundations were liable as transferees...more

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